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TRANSPAC DRILLING VENTURE, 1983-2 v. U.S.

No. 95-5100.

83 F.3d 1410 (1996)

TRANSPAC DRILLING VENTURE, 1983-2 by James M. DOBBINS, Plaintiff-Appellant, v. The UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

May 15, 1996.

Attorney(s) appearing for the Case

Arthur H. Boelter, Boelter & Gale, Seattle, Washington, argued, for plaintiff-appellant.

Pamela C. Berry, Attorney, Tax Division, Department of Justice, Washington, DC, argued, for defendant-appellee. With her on the brief were Loretta C. Argrett, Assistant Attorney General, Gary R. Allen and Gilbert S. Rothenberg, Attorneys.

Before PLAGER, Circuit Judge, FRIEDMAN, Senior Circuit Judge, and CLEVENGER, Circuit Judge.

FRIEDMAN, Senior Circuit Judge.

The question in this case is whether the United States Court of Federal Claims correctly held that assessments of additional partnership tax liability made by the Commissioner of Internal Revenue were timely. See Transpac Drilling Venture, 1983-2 v. United States, 32 Fed. Cl. 810 (1995). The assessments resulted from the disallowance of improperly taken business deductions. We affirm.

I.

A. The basic facts,...

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